ML20062M557

Amend to 810727 Petition to Intervene,Listing Contentions. Affirmation of Svc Encl

ML20062M557
Person / Time
Site:	Catawba
Issue date:	12/09/1981
From:	Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8112170287
Download: ML20062M557 (7)

Text

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U ;ITED STAT',S OF AMERICA NUCLEAR REGULaT0hY COMMISSIO:;

00tKETE USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD M

In'the Matter of

)

'81 DE014 DUKE POWER-COMPANY, et al.,

Docket Nos.

0-gE J [U)NNyc I

(catawba Nuclear Station,

)

v

{;[ ms.unw Units 1 and 2)

)

-s DE016 581* 2 CESG'S CONTENTIONS

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In accord with the Board's Order of Nov. 5, 1981 CES 4 g

herewith amends its petition of July 27, 1981 and contends:

1.

The Board should dismiss Applicant's Application for an Operating License.

The Catawba plant is no.t needed now.

Both Applicant's and Staff's need forecasts made at the CP stage have proved grossly defective as to level of need and i

rate of growth.

CESG's forecast, in contrast, has proved l

l accurate.

The earliest possible date of justifiable operation

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l of Catawba is a decade hence, unless, as appears likely, growth l

in need decreases further.

A realistic, favorable, cost / benefit consideration is rescinding the CP and corhballing the plant until and unles the cost / benefit concideration for continuing l

l construction becomes favorable.

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2.

The license should not issue until and unless the hydrpgen release consequences from that range and variety of LOCA's which the Applicant ic rcquired by the NhC to consider j

have been icalt with co 9r to h.ake ir.possible damage to public health and safety.

The igniter system cannot perform this function.

3 The license should not issue because the risk evaluation made by the Staff is inadequate.

The t'otality of risks, 8112170287 811209 PDR ADOCK 05000413 68 (

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includinC those demonstrated at TMI-2, in relation to.the possible consequences for this specific site, have not.been operating considered.- The/ risks, plus those associated with' decommissioning, the transport, and both interim and long term storage of-I radioactive substances resulting from generation, must be taken i

into consideration in striking a cost / benefit balance vis-a-vis t

' alternatives.

These risks are si6nificant and greater by far' than.those assumed at the CP stage.

It is not within the

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capability of Applicant nor NRC to prove the absence of substantial risks to public health and safety over the period-of time which radioactive materials formed by generation

- remain hazardous.

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_ Motions by Applicant or Staff to dismiss CESG as an

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Intervenor should be denied.

Tnere are sufficient difi'erences in the McGuire and Catawba stations, and sufficient changes in f

both the cost / benefit and safety and health matters for collateral estoppel or res judicata to be inapplicable.

5 The license should not issue because the cost / benefit i

statement has become grossly defective.

Slow construction, due primarily to Applicant's erroneously high forecast of' growth

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in electrical demand, will result in Catawba power being more expensive than a number of alternatives, including conservation and renewable energy sources.

This has been demonstrated by

. Applicant's 10% increase in rate with declaring McGuire, a

~5 plant similarly affected by slow construction, commercial.

6.

The license _should not issue because it will, contrary to the intent of cost / benefit considerations, further burden

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the consumer, not only with construction' costs and the interest on construction borrowing, but with an entirely undeserved-earning on an unneeded facility.

The CP stage cost / benefit statement is grossly defective.

7.

The Board should require the Staff to provide the

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Environmental Impact Statement at least 90 days before the prehearing conference.

This is essential to permit CESG and other petitioners to take into consideration Staff's views in-regard to environmental and health and safety matters.

The existence of an EIS will aid the Board in its consideration of the matters which should be at issue.

8.

If a license issues, it should' require that emergency planning-for the EPZ include the city of Rock Hill.

Because the plant is a low pressure, ice condenser containment type, and because the consequences of severe accidents are estimated to extend to at least 25 miles, a radius of 30 miles should be the basis for emergency planning.

This would include the city of Charlotte.

9.

The EIS should explicitly consider the consequences for the specific site of the entire spectrum of serious release accidents, including PWR-1 to PWR-9 as formulated in the Reactor Safety Study.

This consideration should include the recognition that local officiala and resources are not qualified to assure protection of the public health and safety in the

. event of a serious accident.

10 If a license issues, an adequate crisis relocation plan should.be a condition for issuance.

The nature of parti ~culate releases in serious accidents, such as FWR-1, is such that xx

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relocation of the affected population ~is required. Present plans i

are-deficient in that no consideration is given' crisis relocation.

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11.

The-operating license should not-issue because'part of the construction was not covered in the CP and the CP was t

amended without due process.

The fuel pocl was greatly expanded j

by an anendment.

The Intervenor, CESG, was not, at the time, apprised of this change.

Enlargement of the fuel pool significantly increases the source term for fuel pool accidents, including boiling. dry followed by fuel melt.

12.

A license should not issue because, since the CP stage, in response to the mandates of North Carolina legislation,'the Applicant has embarked on a variety of programs designed to decrease load growth such as load management, special rates for conservers, and a program to assist homeowners in redu'ing thormal c

loss.

The cost / benefit statement of the CP stage was struck absent these considerations.

13 The license should not issue because irregularities in the welding practices on safety related systemn endanger the public henith end safety.

i 14, The prehearing conference should not be held until at least 90 days after the Safety Evaluation P.eport has issued.

CESG has concerns, reflected in some following contentions, which should be addressed by the SEh.

Catawba 15.

The license should not issue because / was designed and is being constructed without appropriate consideration of electromagnetic pulse.

EMP will knock out most of the. power

'6 rids on which Applicant could rely for backup power, knock out

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. 5-m6st if not.all electronic and electric communications systems on which Applicant routinely relies, knock out all control.

f systems relying on solid state components, knock out all computers including the off site computer used for monitoring the ECCS thereby making possible a variety of reactor accidents not forseen including the boiloff of water in the fuel pool.

16.

The license should not issue because the design of the control room preceded knowledge of the essential role of human factors. considerations in design, a factor in the TMI-2 accident and in other operatingproblems having in common avoidable operator error.

17 The license should not issue because no consideration has been.given to the effects of Corbicula, knoNn to infest the Catawba River and Lake Wylie, on the performance of the cooling tower system.

18.

The license should not issue because reactor de6radation in the form of a much more rapid increase inreference temperature than had been anticipated has occurred at a number of PWR's including Applicant's Oconee unit 1.

Until and unless the NRC and the industry can avoid reactor embrittlement, Catawba should not be permitted to operate.

19.

The license should not issue until end unless the loosening of reactor neutron, shield bolting and the loss of such bolts in understood and prevented.

Dropping of the-neutron shield from its support, RESAR Fig. 4.2-7, would result in blockage of the coolant system flow path and, despite the ECCS, lead to a ma'jor LOCA.

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20.

The license'should be withheld as no provision has been made for the release of substantial amounts of radioactivity to l

Lake'Wylie, the source of potable water for many down stream L

. communities.

Such a loss can occur in an accident such as happened at Oconee, in which the quantity of radio active water resulting from washing down a contaminated area exceeded the holding _ capacity, or from any ona of a variety of as yet unencountered operational errors.

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l 21.

The ' license should not issue because Applicant's

. Environmental Report is deficient in that it does not consider the health effects of tritium, considers only airborne volatiles as a source of dosage, ignoring water pathways, and does not consider the consequences of the release of radioactive particulates.

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22.

The licenseshould not issue because.the dilution of f

l ownership was not considered at the CP stage and presents a l

series of problems in connection with responsibility and liabilitty, f

l A-75% interest in Catawba has already been sold.

It is Applicant's

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intention to dispose of the remainder.

As the ter'ms of purchase are unfavorable to the buyers unless Applicant's unrealistic l

forecast of sales eventuates, the owners of the plant will be unable to meet the burdens of ownership, including a proper assumption of liability.

Respectfully submitted,

/,

/2 ( r bq Jesse L. Hiley,/ President,

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Carolina Env't'l. Study Gr'p.

654 Henley Place Charlotte, N.C.

2 207 704-375-h3h2 December 9, 1981 704-55h-31h3

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UNITED STU.

OF AXERICA NUCLEAR REGG. TuhY COMMISSION BEFORE THE ATOMIC SAF M( AND LICENSING E0ARD.jyk(

131-DE014 P4:29 In the Matter of-

)

gjggg

)

o DUKE POWER COMPANY, et nl.,

)

Docket N..ona y Y.d@3.ee.

1

)

DVrAAh

'(Catawba Nuclear Station,

)

Units 1 and 2)

)

AFFIRMATION OF SERVICE I hereby affirm that copies of "CESG'S CONTENTIONS" in the i

above captioned proceeding have been served on the following in the U.S. mail, first class, this 9th day of December, 1981:

James L. Kelley, Chairman ~~~

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~Michacl' McGsFry, III,-Eng.

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Atomic Safety & Licen91ng Board Debevoise and Liberman U.S.

Nuclear Reculatory Commission 1200 17th Street, N.W.

Washington, D.C.

20555 washington, D.C.

20036 Dr. Dixon Callihan William L.. Porter, Esq.

Union Carbide Corporation Albert V.

Carr, Esq.

P.O. Box Y Duke Power Company Oak Ridge, Tennessee P.O. Box 33189 Charlotte, NC 262h2

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Dr. Richard F. Poster P.O. Box 4263 Edward-0. Ketchen, Eng.

Sunriver, Oregon 97701 Counsel for RHC Staff l -

U.S. Nuclear Regulatory Commics.fr.

Atomic Safety + Licencing Appeal Panel Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Robert Guild, Esq.

Attorney-at-Law Atomic Safety & Licensing Board 31h Pn11 Enli l'

Panel Columbia, dC 29201 U.S.

Nuc1cor Regulatory Commission Washin6 ton, D.C.

20555 Palmetto A111anco

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2135t. Devinn Street Docketinc snd cervica Raation Columbin, SC 29205 U.S. HucTear Hegulatory Commission Wachin6 ton, D.C.

20555 Henry Prom er, Chairman Charlotte..eck.

nv ' t '1.

Con 11 tie-

.hichard P. Wilson, 9!;2 Henley Place

~ Esq.

A:nistant Attorney General Chnriotte, NC 28207 2600 ha13 street

[

Columbin, SC 29201

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.N Je5ne I., biley for,C/.SG f

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